City of Birmingham v. Drummond

RICE, Judge.

Appellee had judgment against appellant, in a suit for damages for personal injuries, based on the verdict of a jury, in the sum of $500.

Her complaint, consisting of but a single count, considered in connection with the exhibit accompanying it, and incorporated in it by reference (Grimsley v. First Ave. Coal & Lumber Co., 217 Ala. 159, 115 So. 90), averred — in addition to cataloging her injuries — as follows, to-wit:

“That the City of Birmingham failed to erect proper barricades, cross-walks and take other necessary steps for the prevention of accidents to pedestrians at the…